If the current situation of 103/8 distribution is different from the intention
and concept of prop-062(*) as described in the proposal, I think we need to 
discuss it
and revise the policy as necessary.

  (*)103/8 block is intended to accommodate minimum IPv4 address block
     for new comers.

     prop-062: Use of final /8
     https://www.apnic.net/policy/proposals/prop-062

I think our community is responsible for maintaining the number resources 
policy.
Regardless of IPv4 or IPv6, it is not appropriate to leave the policy untouched,
and not to maintain what we have developed.

Regards,
Hiroki

Subject: Re: [sig-policy] New version of prop-116: Prohibit to transfer IPv4 
addresses in the final /8 block (SECURITY=UNCLASSIFIED)
From: Mark Foster <[email protected]>
Date: Tue Sep 27 2016 09:14:57 GMT+0900

I agree that there's an element of 'deck chair rearrangement' but it's a 
reality that there is a commercial market for IPv4 and competitive value in 
having addresses available. To simply say 'who cares about IPv4, move on' will 
simply encourage predatory practices.

I have no doubt that the M&A process will be used to abuse the process, and 
believe there needs to be a deterrent to the abuse of the bureaucratic process.
But legitimate M&A needs to be permitted (having had to engage this process in 
the last couple of years due to organisational and commercial changes at my 
then-employer, I wouldn't want to see that process made any more complex than 
necessary).

I think that the modified proposal has merit for that reason, and would support 
it.

Mark.


On Tue, Sep 27, 2016 at 8:50 AM, Alastair Johnson <[email protected] 
<mailto:[email protected]>> wrote:

    I agree with Mike. I don't support this proposal.

    AJ

    On Sep 26, 2016, at 2:26 PM, HENDERSON MIKE, MR <[email protected] 
<mailto:[email protected]>> wrote:

    The objectives of this proposal are laudable, but in my view policy 
development for IPv4 is just ‘rearranging the deck chairs on the Titanic’: a 
waste of time and effort.____

    __ __

    __ __

    I do *not* support this proposal____

    __ __

    __ __

    Regards____

    __ __

    __ __

    */Mike/*____

    __ __

    *From:*[email protected] 
<mailto:[email protected]> 
[mailto:[email protected] 
<mailto:[email protected]>] *On Behalf Of *Masato Yamanishi
    *Sent:* Monday, 26 September 2016 11:06 p.m.
    *To:* [email protected] <mailto:[email protected]>
    *Subject:* [sig-policy] New version of prop-116: Prohibit to transfer IPv4 
addresses in the final /8 block____

    __ __

    Dear SIG members

    A new version of the proposal "prop-116: Prohibit to transfer IPv4
    addresses in the final /8 block" has been sent to the Policy SIG for
    review.

    Information about earlier versions is available from:

    http://www.apnic.net/policy/proposals/prop-116 
<http://www.apnic.net/policy/proposals/prop-116>

    You are encouraged to express your views on the proposal:

     - Do you support or oppose the proposal?
     - Is there anything in the proposal that is not clear?
     - What changes could be made to this proposal to make it more effective?

    Please find the text of the proposal below.

    Kind Regards,

    Masato, Sumon

    -------------------------------------------------------

    prop-116-v002: Prohibit to transfer IPv4 addresses in the final /8 block

    -------------------------------------------------------

    Proposer:       Tomohiro Fujisaki
                    [email protected] <mailto:[email protected]>




    1. Problem statement
    --------------------

    There are a lot of transfers of IPv4 address blocks from 103/8
    happening, both within the APNIC region and among RIRs.

    Then number of transfer from 103/8 block are about 200, which is
    about 12% of the total number of transfers. This looks so hight
    high, since APNIC manages about 40/8.

    And based on the information provided by APNIC secretariat, number
    of transfers from the 103/8 block are increasing year by year.

    Provided by George Kuo on the sig-policy ML at 8th September 2016:

    1) M&A transfers containing 103/8 space

    +------+-----------+-----------+-
    |      |   Total   | Number of |
    | Year | Transfers |   /24s    |
    +------+-----------+-----------+-
    | 2011 |         3 |         12 |
    | 2012 |        10 |         46 |
    | 2013 |        18 |         66 |
    | 2014 |       126 |        498 |
    | 2015 |       147 |        573 |
    | 2016 |        45 |        177 |
    +------+-----------+------------+-

    2) Market transfers containing 103/8 space

    +------+-----------+-----------+
    |      |   Total   | Number of |
    | Year | Transfers |   /24s    |
    +------+-----------+-----------+
    | 2011 |         2 |         2 |
    | 2012 |        21 |        68 |
    | 2013 |        16 |        61 |
    | 2014 |        25 |        95 |
    | 2015 |        67 |       266 |
    | 2016 |        56 |       206 |
    +------+-----------+-----------+


    And also, transfers from the 103/8 block include:
      - Take place within 1 year of distribution, or
      - Multiple blocks to a single organization in case of beyond 1 year.

    Further, there is a case where a single organization have received 12
    blocks transfers from 103 range.

    see:  https://www.apnic.net/transfer-resources/transfer-logs 
<https://www.apnic.net/transfer-resources/transfer-logs>

    From these figures, it is quite likely that substantial number of 103/8
    blocks are being used for transfer purpose.

    This conflicts with the concept of distribution of 103/8 block
    (prop-062), which is intended to accommodate minimum IPv4 address blocks
    for new comers.

     prop-062: Use of final /8
     https://www.apnic.net/policy/proposals/prop-062 
<https://www.apnic.net/policy/proposals/prop-062>


    2. Objective of policy change
    -----------------------------

    When stated problem is solved, distribution from 103/8 block will be
    consistent with its original purpose, for distribution for new entrants
    to the industry. Without the policy change, substantial portion of 103/8
    blocks will be consumed for transfer purpose.


    3. Situation in other regions
    -----------------------------

    RIPE-NCC has been discussing to prohibit transfer under the final /8
    address block.


    4. Proposed policy solution
    ---------------------------

    Prohibit transfer IPv4 address under /8 address block (103/8).
    If the address block allocated to a LIR is not needed any more, it have
    to return to APNIC to allocate to another organization.

    In the case of transfers due to M&A, merged organization can have
    up to /22 IPv4 address in the 103/8 block. The 103/8 IPv4 address
    more than /22  have to return to APNIC to allocate to another
    organization.


    5. Advantages / Disadvantages
    -----------------------------

    Advantages:
      - It makes 103/8 blocks available according to the original purpose,
        as distribution for new entrants (rather than being consumed for
        transfer purpose)

      - IPv4 addresses under final /8 are not transferred to outside APNIC.

      - By prohibiting transfer them, it is possible to keep one /22 for
        each LIRs state,  which is fair for all LIRs.

    Disadvantages:

    None.


    6. Impact on resource holders
    ------------------------------

      - LIRs cannot transfer address blocks under 103/8. No big impact while
        they use it.

      - Organizations which needs to receive transferred IPv4 can continue
        to do so, outside 103/8 blocks (which should be made available for
        new entrants)


    7. References
    -------------____

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